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Load Line Length - Policy Clarification - Hullform Cut- Outs, Extensions and Steps

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Load Line Length - Policy Clarification - Hullform Cut- Outs, Extensions and Steps Maritime and Coastguard Agency LogMARINE GUIDANCE NOTE MGN 645 (M) Load Line Length - Policy Clarification - Hullform Cut- Outs, Extensions and Steps Notice to all Owners and builders of Small Commercial Vessels, Shipowners, Designers, Masters, Assigning Authorities and Surveyors This notice should be read with.. The Merchant Shipping (Load Line) Regulations 1998 - SI 1998 No.2241, as amended The Safety of Small Commercial Motor Vessels - A Code of Practice (Yellow Code) The Safety of Small Commercial Sailing Vessels - A Code of Practice (Blue Code) The Safety of Small Workboats and Pilot Boats - A Code of Practice (Brown Code) The Code of Practice for the Safety of Small Vessels in Commercial Use for Sport or Pleasure Operating from a Nominated Departure Point (Red Code) MGN280: Small Vessels in Commercial Use for Sport or Pleasure, Workboats and Pilot Boats - Alternative Construction Standards Summary This Note clarifies the UK policy when determining Load Line Length on vessel hullforms featuring cut-outs, removable end sections, or bathing platforms. 1. Foreword 1.1 This MGN relates to vessels with under 24m in Load Line Length, where the keel of which was laid on or after the date these regulations were implemented and were measured in accordance with the regulations in force at that time. 2. Introduction 2.1 Load Line Length (L) is used as a breakpoint for determining whether a vessel should comply with the requirements for either small vessels or large vessels. Identifying this size breakpoint is particularly important when the determination of the length of the vessel on the 85% waterline or identification of the point of least moulded depth is not straight forward due to particular design arrangements. The objective of this MGN is to explain how the MCA will interpret L in respect of design / measurement practices and the circumstances in which certain measurements will be applied. 1 2.2 The 24m L breakpoint provides a minimum limit to the size of vessel within the scope of the International Convention on Load Lines (Load Lines 66/88), which applies to certain new internationally trading vessels of 24m L and over. An example of how the breakpoint applies in the UK is that the MCA Small Commercial Vessel Codes of Practice apply to seagoing commercial vessels of less than 24m L as an alternative to compliance with the relevant UK Load Line Regulations. This is considered a proportionate approach because the UK Load Line Regulations can be considered overly onerous to apply. 2.3 Load Lines 66/88 and the UK Load Line Regulations (SI 1998 No.2241, as amended by S.I. 2000/1335), define L as: "length" and "(L)" in relation to a ship means the greater of the following distances:- 96% of the total length on a waterline at 85% of the least moulded depth measured from the top of the keel; or the length from the foreside of the stem to the axis of the rudder stock on that waterline. In practice, this would mean that where the stem contour is concave above the waterline at 85% of the least moulded depth, both the forward terminal of the total length and the fore-side of the stem respectively shall be taken at the vertical projection to that waterline of the aftermost point of the stem contour (above that waterline) (see Figure 1). Figure 1: Example of length where the stem contour is concave In ships designed with a rake of keel the waterline on which this length is measured shall be parallel to the designed waterline at 85% of the least moulded depth (Dmin). This can be found by drawing a line parallel to the keel line of the vessel (including skeg) tangent to the moulded sheer line of the freeboard deck. The least moulded depth is the vertical distance measured from the top of the keel to the top of the freeboard deck beam at side at the point of tangency (see Figure 2). - 2 - Figure 2: Waterline at 85% of the least moulded depth 2.4 The MCA has become aware of vessels with cut-outs in way of the 85% waterline such that 96% of the length on that waterline is less than 24m. The cut-out arrangement can lead to undesirable hydrodynamic characteristics or aesthetic considerations so the cut- out is typically covered with a fairing piece which follows the more usual contours of a stem or stern. This fairing piece is generally bolted or otherwise fixed in place for the duration of the vessel’s life and, with the fairing piece in place and included in L calculations, the L of the vessel would be 24m or above. This is illustrated in Figures 3 and 4 below. Figure 3: Vessel Bow cut-out on the 85% Waterline Figure 4: Waterline Length in Relation to Bow Cut-out 2.5 Other examples have been seen where one or both end sections of a vessel are bolted- on (or otherwise fixed) at a vertical flat-plane bulkhead to artificially increase the length of a vessel with an allegedly “removable” portion of hull which has been discounted from L calculations. This is similar to the example at 1.4 above but without the cut-out, and for similar reasons as described above for a fairing, the “removable” stem or stern portion(s) - 3 - will clearly be in place during the normal operation of the vessel and may well be fixed in place for the duration of the vessel’s life. 2.6 As can be seen by the definition at 1.3 above, determination of L requires the least moulded depth to be ascertained. If the least moulded depth, and hence the 85% waterline, falls on an extended low deck such as a bathing platform then the vessel will be considerably longer than if the bathing platform were excluded from the length determination. Section 4 of this MGN clarifies the circumstances under which low deck extensions such as bathing platforms should be taken into account when determining L. Figure 5 demonstrates how the length of the vessel can be altered by the inclusion or omission of the bathing platforms. Figure 5: Influence of “bathing platform” on Load Line Length 2. UK Policy on Reduction of Length Through Cut-Outs 2.1 The part-definition of ‘fixed permanent structure’ as given in the Merchant Shipping (Tonnage) Regulations, Statutory Instrument 1997 No. 1510 (as amended) which is associated with the measurement of Load Line Length, explains that a ‘’fixed permanent structure" includes any portion of the hull which is capable of being detached, but which is fixed in place during the normal operation of the vessel. Any addition or arrangement on the bow or stern of the vessel, the effect of which is to change the calculation of the Load Line Length of the vessel and is normally in position when the vessel is navigating, will be taken into account in the calculation of length whilst in its operating position. 2.2 With the above regulations and policy in mind, cut-outs in the stem or stern, as described in para 1.4 of this MGN, which serve no functional purpose for the design of the vessel, and exist solely to circumvent the requirement for vessels of 24m and over to comply with Load Lines 66/88, will be treated as if they do not exist for the purpose of measuring Length. As a result, for vessels where the cut-out portion on the 85% waterline has been covered with a fairing piece, the MCA and organisations authorised by the MCA will consider the L of a vessel to be the length with the fairing piece in place. Cut-outs will only be considered as a genuine reduction in L if they serve a purpose; for example an anchor housing. All UK authorised assigning authorities are encouraged to apply this policy. 3 UK Policy on Extension of Length Through Removable End Sections 3.1 Any portion of the hull which is capable of being detached, but which is fixed in place during the normal operation of the vessel, is included in the definition of ‘fixed permanent structure’. Fixed permanent structures which are in way of a waterline at 85% of the least - 4 - moulded depth measured from the top of the keel, should be included in the calculation of L. All UK authorised assigning authorities are encouraged to apply this policy. 3.2 The policy above is not intended to apply to functional arrangements such as Trim Tabs but it is expected to be applied to all fixed permanent structure from the date of this MGN. 4 UK Policy on Extension of Length Through Bathing Platforms and Low Decks 4.1 Bathing platforms have in the past been excluded from the Load Line Length. This has tended to encourage disproportionately long lengths whilst allowing the craft to nominally remain below the 24 metres breakpoint referred to in paragraph 1.2 above. 4.2 Where a platform is clearly an appendage that does not contribute towards the buoyancy of a vessel, then it should not be considered as part of the Load Line Length. Where the platform cuts the waterline and therefore contributes towards buoyancy, it should be considered as being part of the Load Line Length, regardless of whether it is full width or whether it is bolted on. 5 Length Measurement – RCD and Load Line 5.1 Hull Length. LH defined for the Recreational Craft Directive in ISO Standard 8666:2018 is as follows: a. Measured parallel to waterline. b. This length includes all structural and integral parts of the craft, such as stems or sterns, bulwarks, and hull/deck joints.
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